ML20151G656
| ML20151G656 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/18/1988 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Gleason J, Kline J, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| CON-#388-6774 OL-3, NUDOCS 8807290064 | |
| Download: ML20151G656 (15) | |
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8357 James P.
Gleason, Chairman Dr. Jerry R.
Kline By Hand Mr. Frederick J.
Shon Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Suffolk County Emergency Operations Plan
Dear Judge Gleason and Members of the Board:
This letter will sammarize the knowledge of LILCO and of its counsel concerning the alleged request for and receipt of the Suffolk County Emergency Operations Plan (SCEOP) by a LILCO em-ployee, Norman Kelly, in 1985 or 1986, outside of formal discov-ery processes.
That allegation was first made by Intervenors on June 28, 1988 and does not address the basic issue -- whether that composite document was, in ' fact, ever provided to LILCO in discovery prior to late May of'this year.
Nonetheless, the pur-pose of this letter and of the attached Affidavit of John A.
Weismantle is to flesh out the facts on this issue, as best they have been able to be determined, in an inquiry be or about June 28 and completed only last week.1/ gun by LILCO on Mr. Kelly, the only witness requested f rom LILCO by the Board, testified last Thursday, July 14, as to matters within his knowledge.
However, he was not in a position, because of the limited nature of his responsibilities at LILCO, to describe LILCO's inquiry.
That description follows.
1/
In the interest of expedition, Mr. Weismantle's Affidavit is being submitted now in unsigned and un-notarized form.
It will be submitted with signature and notarization as soon as possible, 3g0h h
P o
4 H UNTON & WILLIAu s July 18,1988 Page 2 Immediately upon receipt of Intervenors' June 28 pleading, inquiries were begun by LILCO personnel, at the direction and with the assistance of counsel, to attemp-to understand'any pos-sible basis for Intervenors' allegation.
The first series of in-quiries was'to Mr. Kelly; his knowledge is reflected in his tes-timony of last week.
Because Mr. Kelly was unable (either upon inquiry within LILCO or in testimony last week) to recall definitively either who had requested him to obtain emergency planning documents in 1985-86, exactly what documents he had obtained, to whom he had provided them, or for what purpose, LILCO's internal inquiry was expanded to include the following questions:
1.
Was the composite SCEOP as received in May and then in July 1988 (which, apparently, was the same basic form and length as it existed in 1985) among the documents held anywhere within LILCO's emergency planning group (the Local Emergency Response Implementing Organization, or LERIO) prior to late May 1988?
2.
Did anyone in LERIO now or in the 1985-86 period, who now occupies or then occupied a position with actual or apparent authority to instruct Norman Kelly to attempt to obtain the SCEOP, ever ask him to do so?
3.
If there is no copy of the composite SCEOP in LERIO files, is there one anywhere else among LILCO files?
4.
Could there have been reasons other than the Shoreham case, involving parts of LILCO other than LERIO, for inquiry into the existence and nature of Suffolk County emergency plans?
5.
If so, does anyone in such other parts of LILCO recall having requested Norman Kelly, directly or indirectly, to obtain Suffolk County emergency planning documents?
These inquiries produced the following answers:
1.
No.
A complete search of LERIO records predating late May 1988 failed to disclose any trace of the composite SCEOP.
The composite document was not in LERIO files before late May 1988.
The fragments of it which LERIO possessed before May 1988 did not include the entire SCEOP, and did not go in fact beyond the fragments provided voluntarily by LILCO on July 9, 1988 under cover of a letter from Mr. Sisk to Mr. Lanpher, and introduced as Suffolk County Discovery Exhibit 1.
a H UNTON & WILLIAu s July 18, 1988 i
Page 3 2.
No.
No one now in authority in LERIO, or in LERIO in 1985-86, recalls having asked Mr. Kelly in the 1985-86 period to attempt to obtain a copy of the Suffolk County Emergency Op-1 erations Plan by name or description.
The persons inquired of included the following present LILCO employees:
John Weismantle, Charles Daverio, Douglas Crocker.
It included the following former LILCO employees and consultants:
Elaine Robinson, William Renz.
It included the following LILCO consultants:
Brant Aidikoff, Dennis Behr.
No one now or then in a position to have initiated the request to Mr. Kelly was knowingly omitted.
None of the persons interrogated can recall having requested Mr. Kelly to make the request for the SCEOP in 1985-86, or at any other time.
Questions were specifically asked as to whether there had been an inquiry in connection with the February 1986 exercise; the answer was in the negative.
Mr. Aidikoff recalls having asked Mr. Kelly in 1987 to try to obtain a County organization chart and (as indicated in Mr. Kelly's testimony on July 14)
Mr. Kelly obtained the County's Emergency Directory.
3.
No.
No copies of the Suffolk County Emergency Opera-tions Plan have been located anywhere else in LILCO's files.
4.
Yes.
There were two other projects independent of Shoreham which involved attention to emergency preparedness in the 1985-86 time frame.
The first was a task force on hurricane preparedness assembled after Hurricane Gloria in October 1985.
The second was emergency preparedness for a liquefied natural gas (LNG) facility owned by LILCO in Holtsville.
These projects were ongoing in late 1985 and early 1986.
They were directed by per-sonnel elsewhere in LILCO, though some present and former LERIO personnel, primarily Ms. Robinson, were consulted on them.
Records of these projects were kept separately from LERIO records.
5.
No.
Inquiries of key personnel involved in the Hurri-cane Gloria and Holtsville projects and searches of the projects' records have been made since June 28.
No one recalls making the request at issue; no copy of the SCEOP or any of its fragments has been located in the records of either of these projects.
Ms. Robinson recalls having requested copies of the emergency plans for the towns of Islip and Brookhaven in connection with the Holtsville project; she has no recollection of having ever asked for or received the SCEOP or other documents from Suf folk County.
HUNTON & WILLIAMS
]
l July 18,1988 Page 4 The foregoing matters are attested to by the attached Affi-davit of John A. Weismantle.
Further, confirmatory inquiries l
have also been made on this natter to knowledgeable attorneys within Hunton & Williams.
No attorney at the firm ever requested l
or knew of a request to Mr. Kelly F.o obtain the composite SCEOP, l
l and no one at the firm had ever seen the composite SCEOP before late May 1988.
l While this issue is peripheral to the one of compliance with formal discovery requests, LILCO does not wish to leave the pres-l ent record unclear.
Whatever the remaining uncertainties, it is the case that no one at LILCO or LILCO's counsel recalls having ever seen the composite SCEOP before May 1988, and that no one recalls having asked Mr. Kelly, directly or indirectly, to obtain it.
l Finally, the Board may recall a request from Staff counsel last week for what she described as an "index to the index" of the SCEOP, relating those portions received by LILCO in formal discovery to the overall contents of the document.
While that information has already been provided in various places, the at-l tached table entitled "Suffolk County Emergency Operations Plan (Version Produced to LILCO on July 8, 1988)" summarizes the mat-ter.
As it indicates, LILCO received in total some 161 pages of the 762 pages of the SCEOP, in 9 increments over the course of two years.
l Respectf 11 s
- mitted, Donald P.
Irwin One of Coun'sel for Long Island Lighting Company Attachments
{
LILCO, July 18,1988 IJNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
{
l In the Matter of
)
)
1 LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3 l
) (Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
AFFIDAVIT OF JOHN A. WEISMANTLE l
John A. Weismantle, being duly sworn, deposes and says as follows:
l l
1.
My name is John A. Weismantle. My business address is 175 East Old Coun-try Road, Hicksville, New York. My position is Vice President - Research and Devel-opment and Corporate Studies for Long Island Lighting Company. I have been involved with offsite emergency planning for the Shoreham Nuclear Power Station since 1982 and with the functioning of LILCO's Local Emergency Response Implementing Organi-zation, or LERIO, since its inception in 1983, and was the original Manager of LERIO.
l LERIO is the organization responsible for developing and implementing the Offsite Ra-l dialogical Emergency Response Plan for Shoreham.
l 2.
I make this affidavit in order to summarize the results of an inquiry under-taken by LILCO, at the direction and with the assistance of counsel, beginning almost immediately upon receipt of Intervenors' June 28 pleading asserting that LILCO had ob-tained a complete copy of the Suffolk County Emergency Operations Plan (SCEOP) via a LILCO employee, Norman Kelly, outside of formal discovery processes in this pro-ceeding, in either late 1985 or early 1986.
r 8
. 3.
Mr. Kelly was first shown a copy of the SCEOP and of Intervenors' June 28
)
pleading on June 29, and was asked to identify the document if he could and to cast light on the remaining allegations in the June 28 pleading. He testified last Thursday, July 14, as to matters within his knowledge. He was not in a position, because of the limited nature of his responsibilities at LILCO, to describe either the entire range of LILCO's emergency preparedness knowledge or of LILCO's inquiry concerning the SCEOP.
Mr. Kelly administers basic LERO training, and also updates an annual farmstand survey for the 50-mile ingestion pathway EPZ and oversees the EPZ siren maintenance program. However, he is not involved in planmng or decision-making in
- LERIO and has never been a witness in this proceeding.
4.
When the limitations on Mr. Kelly's knowledge became apparent, LILCO's inquiry was broadened to include the following questions:
A.
Was the composite Suffolk County Emergency Operations Plan as re-ceived in May 1988 among the documents held anywhere within LERIO prior to late May 19887 B.
Did anyone in LERIO now or in the 1985-86 period, who now occupies or then occupied a position with actual or apparent author-ity to instruct Norman Kelly to attempt to obtain the SCEOP, ever ask him to do so?
C.
If there is no copy of the composite Suffolk County Emergency Op-erations Plan in LERIO files, is there one anywhere else among LILCO files?
D.
Could there have been reasons other than the Shoreham case, involving parts of LILCO independent of LERIO, for inquiry into the existence and nature of Suffolk County emergency plans?
E.
If so, does anyone in such other parts of LILCO recall having re-quested Norman Kelly to obtain Suffolk County emergency planning documents?
5.
These inquiries produced the following answers:
A.
No. A complete search of LERIO records predating late May 1988 failed to disclose any trace of the composite SCEOP. The composite document was not in LERIO files before late May 1988. The frag-ments of it which LERIO possessed before May 1988 did not include the entire SCEOP, and did not go in fact beyond the fragments pro-vided voluntarily by LILCO counsel in a letter from Mr. Sisk to Mr.
Lanpher dated July 9.
m o
. B.
No. No one now in authority in LERIO, or in LERIO in 1985-86, recalls having asked Mr. Kelly in the 1985-86 period to attempt to obtain a copy of the Suffolk County Emergency Operations Plan by name or description. The persons inquired of included the following present LILCO employees:
John Weismantle, Charles Daverio, Douglas Crocker. It included the following former LILCO employees and consultants, who came to Long Island on July 7 for a face-to-face meeting on the matter: Elaine Robinson, William Renz. It in-cluded the following LILCO consultants:
Brant Aldikoff, Dennis Behr. No one now or then in a position to have initiated the request to Mr. Kelly was omitted.
None of the persons interrogated can recall having requested Mr. Kelly to make the request for the SCEOP in 1985-86, or at any other time. Questions were specifically asked as to whether there had been an inquiry in connection with the February 1986 offsite emergency preparedness exercise. The an-swer was in the negative.
Mr. Aldikoff recalls having asked Mr. Kelly in 1987 to try to obtain a County organization chart and (as indicated in Mr. Kelly's testimony on July 14) Mr. Kelly obtained the County's Emergency Directory.
C.
No. No copies of the Suffolk County Emergency Operations Plan have been located anywhere else in LILCO's files.
D.
Yes. There were two other projects independent of Shoreham which involved attention to emergency preparedness in the 1985-86 time frame. The first was a task force on hurricane preparedness assem-bled af ter Hurricane Gloria in October 1985. The second was emer-gency preparedness for a liquefied natural gas (LNG) f acility owned by LILCO in Holtsville. These projects were ongoing in late 1985 and early 1986.
They were directed by personnel elsewhere in LJLCO, though some present and former LERIO personnel, primarily Ms. Robinson, were consulted on them. Records of them were and are kept separately from LERIO records.
E.
No. Inquiries of key personnel involved in the Hurricane Gloria and Holtsville projects and searches of the projects' records have been made since June 28. No one recalls making the request at issue; no copy of the SCEOP or any of its fragments has been located in the records of either of these projects. Ms. Robinson recalls having re-quested copies of the emergency plans for the towns of Islip and Brookhaven in connection with the Holtsville project; she has no recollection of having ever asked for or received the SCEOP or other documents from Suffolk County.
6.
I had never seen the composite SCEOP before late May 1988. Though I was aware of the existence of documents which have turned out to be fragments of it, I had no knowledge before May 1988 that they fit together into a composite whole. The identity of whoever (if anyone) requested Mr. Kelly to attempt to obtain the SCEOP in
..- 1985-86 or at any other time has not been disclosed by a review of all knowledgeable persons who could be interviewed. Nor could the recipient of the SCEOP, if it was ob-tained. It does not exist in any LILCO files in any area where it might logically be 10-cated.
John A. Weismantle Subscribed and sworn before me this day of July,1988.
My commission expires:
Notary Public l
l
Suffolk County Emergency Operations Plan (Version Produced to LILCD on July 8, 1988)
Corresponding or Potentially No. of Pages Corresponding Document Produced of Previously Section Title Description; No. of Pages to LILCD in 1982-83 Discovery Produced Document Teble of Contents Four (4) pages A.
General 1.
Introduction - Prepared by State; Eight (8) pages A.
General 2.
Basic Plan - Prepared by State; Twenty-one (21) pages A.
General 3.
Legislative Authority -
Legal Statutes Signed into Law; Sixteen (16) pages Annex A Command and Control; Eight (8) pages Annex A "Not applicable to the Appendix 1 County"; One (1) page Annex A "Not applicable to the Appendix 2 County"; One (1) page Attachments i
a,b,c
.l Annex A Succession to Conmand Emergency Operations Plan One (1) page Appendix 2 Lines of Succession to the Annex A, App. 2, Att. D (for j
Attachment d Local Chief Executive and Police Department only);
Officials; Thirty-four follows SC Bates No. 000090 (34) pages (Produced in 1983)
. Corresponding or Potentially No. of Pages Corresponding Dormaant Produced of Previously Section Title Description; Mo. of Pages to LILCD in 1982-83 Discovery Produced Doctament Annex A Local Law Establishing Appendix 2 Lines of Succession; Attachment e Ten (10) pages Annex A Line of Authority; Appendix 3 Six (6) pages Annex A Local Executive Orders; Standard Operating Procedure Five (5) pages Appendix 4 Standard Operating for Use in the Event of Procedure for Use in the Natural Disasters, Man-V.ade Event of Natural Disasters, Disasters and Nuclear Attack; Man-Made Disasters and SC Bates No. 000266 (Produced Nuclear Attack; Twenty-one in 1982 and 1983)
(21) pages Annex A Jurisdictions; Appendix 5 Four (4) pages Annex A EOC Floor Plan; Appe.xlix 6 Four (4) pages Annex A Division of Emergency Department of Emergency Thirty-seven Appendix 7 Preparedness Emergency Preparedness Emergency (37) pages Directory; Thirty-one Directory; SC Bates No.
(31) pages 4060213 (Produced in 1982)
Annex A Increased Readiness Disaster Action for Two (2) pages Appendix 8 and Attack Warning; County, Townships, and Three (3) pages Villages Governmental and Emergency Prepared-t ness Personnel; follows SC Bates No. 000173 (Produced in 1983) i
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- Corresponding or Potentially No. of Pages Correspondine Document Produced of Previously Section Title Description; No. of Pages to LILCD it: 1982-83 Discovery Proluced Document Annex B Administration Section; Nine (9) pages Annex C Civil Air Patrol; Twenty-two (22) pages Annex D Communications and Warning System; Fifty-one (51) pages Annex E Fire Service; Six Hurricane Disaster Plan Three (3) pages (6) pages Fire Island, New York Fire Service; SC Bates No.
001727 (Produced in 1983)
Annex F Health Service; Eleven (11) pages Annex G Manpower Service; Ten (10) pages Annex H Police Service; Police Service; follows Sixteen (16) pages
'1hirty-six (36) pages SC Bates No. 000090 (Produced in 1983)
Annex H-1 Sheriff's Department; Emergency Preparednors Seven (7) pages Twenty (20) pages Emergency Operations Plan for Suffolk County Sheriff's Office Riverhearl, New York; follows Bates No. 000938 (Produced in 1983)
.4
... Corresponding or Potentially No. of Pages Corres W ing Document Produced of Previously Section Title Description; Mo. of Pages to LILQ) in 1982-83 Discovery Prcduced Doctement Annex I Public Information Service l
l Four (4) pages l
Annex J Public Works Service; Ten (10) pages Annex K Radiological Intelligence Section (not included with EOP) One-hundred and Sixty (160) pages l
Annex L Rescue Service; Fifteen (15) pages i
Annex M Resources Section; Nine (9) pages Annex N School Service; Twenty-seven (27) pages Annex 0 Social Services Section; Thirty-seven (37) pages Annex P Community Shelter Plan -
"See Volume 2" (not incitxled with EOP)
.C Annex Q Crisis Relocation Plan -
"See Volume 3" (not included with EOP) styrAL PAGES:
762 161
p1A LILCO, July 19,1988 l'OLMEi LC UWkC CERTIFICATE OF SERVICE OFFIE e SS eib !
00CKEim e TiW!CI BRANL" In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of a letter from Donald P. Irwin, Esq. to James P.
Gleason, Chairman, et al., with accompanying Affidavit of John A. Weismantle and a table entitled "Suffolk County Emergency Operations Plan (Version Produced to LILCO on July 8,1988)" were served this date upon the following by hand as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, post-age prepaid.
James P. Gleason, Chairman
- Adjudicatory File Atomic Safety and Licensing Board Atomic Safety and Licensing 513 Gilmoure Drive Board Panel Docket Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline
- Atomic Safety and Licensing Edwin J. Reis, Esq.
- Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of the General Counsel East-West Towers, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.
Bethesda, MD 20814 Herbert H. Brown, Esq.
- Lawrence Coe Lanpher, Esq.
Mr. Frederick J. Shon
- Karla J. Letsche, Esq.
Atomic Safety and Licensing Kirkpatrick & Lockhart Board South Lobby - 9th Floor U.S. Nuclear Regulatory Commission 1800 M Street, N.W.
East-West Towers, Rm. 430 h ashington, D.C. 20036-5891 4350 East-West Hwy.
Bethesda, MD 20814 Fablar. G. Palomino, Esq.
- Richard J. Zahnleuter, Esq.
Secretary of the Commission Special Counsel to the Governor Attention Docketing and Service Executive Chamber Section Room 229 U.S. Nuclear Regulatory Commission State Capitol 1717 H Street, N.W.
Albany, New York 12224 Washington, D.C. 20555 Alfred L. Nardelli, Esq.
Atomic Safety and Licensing Assistant Attorney General Appeal Board Panel 120 Broadway U.S. Nuclear Regulatory Commission Room 3-118 Washington, D.C. 20555 New York, New York 10271
q Ps:
y George W. Watson, Esq.
- Ms. Nora Bredes William R. Cumming, Esa.
Executive Coordinator Federal Emergency Mar.gement Shoreham Opponents' Coalition Agency 195 East Main Street 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 Evan A. Davis, Esq.
Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 E. Thomas Boyle, Esq.
Stephen B. Latham, Esq. **
Suffolk County Attorney Twomey, Latham & Shea Building 158 North County Complex 33 West Second Street Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11788 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire Nnrth Shore Committee Federal Emergency Management P.O. Box 231 Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 Jonathan D. Feinberg, Esq.
New York State Department of Public Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223 L~ M Donald P. Irwin Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: July 19,1988